Chris Hutley-Hurst
Partner
Guernsey
Guernsey has moved quickly to implement the OECD’s Crypto-Asset Reporting Framework (CARF), marking a further significant development for the island’s financial and digital asset sectors. Regulations implementing CARF in Guernsey were made on 30 December 2025 and came into force on 1 January 2026. This follows Guernsey signing the Multilateral Competent Authority Agreement in November 2024 and committing to a common implementation timeline alongside other jurisdictions.
The aim is clear: align Guernsey with global standards on tax transparency and automatic exchange of information for crypto-asset transactions.
Key dates for Guernsey
- 1 January 2026: First CARF reporting period began.
- 2027: First international exchanges of information expected.
Who is in scope?
CARF applies to entities that provide services enabling crypto-asset exchange or transfer on behalf of customers. Examples of in-scope entities include:
- Crypto-asset exchanges
- Brokers and dealers facilitating crypto transactions
- Intermediaries offering transfer services
Not every business dealing with crypto will fall under CARF. For instance, investment funds holding crypto assets may be out of scope if investors do not directly execute, exchange, or transfer transactions. Conversely, businesses purchasing crypto assets for onward distribution may be captured. Each entity must review its activities against the definition of a Reporting Crypto-Asset Service Provider (RCASP).
What are the obligations?
Businesses identified as RCASPs will need to meet three core obligations:
- Collect client self-certifications including tax residency and tax identification numbers.
- Conduct due diligence to identify reportable customers and controlling persons.
- Report annually to the Guernsey Revenue Service on relevant transactions.
Transactions covered include:
- Crypto-to-crypto exchanges
- Fiat-to-crypto and crypto-to-fiat exchanges
- Transfers of crypto assets, including to unhosted wallets
Exclusions?
Not all digital assets fall under CARF. Central Bank Digital Currencies and certain electronic money products are excluded, although they will be reportable under the expanded CRS rules. CARF focuses on decentralised assets that can be transferred without traditional intermediaries. Crypto-assets that cannot be used for payment or investment purposes also fall outside of CARF.
Next steps for Guernsey businesses
With the first reporting period starting in January 2026, businesses should act now to:
- Assess RCASP status and determine whether their activities fall within scope.
- Implement compliance frameworks, including policies, procedures, and staff training for onboarding and reporting.
- Monitor updates from the Guernsey Government and OECD to stay aligned with evolving requirements.
Failure to prepare could lead to compliance risks and reputational impact as global tax transparency standards tighten.
CARF represents a major shift for Guernsey’s crypto sector, and is being implemented whilst the Guernsey Financial Services Commission looks to drive future growth and position Guernsey as a trusted, innovative hub for digital finance and digital assets (further information can be found here). The island’s commitment to implementing CARF reinforces its position as a well-regulated jurisdiction. Businesses should prioritise readiness for the 2026 reporting cycle.
Global advisory
For full details on the Crypto Asset Reporting Framework, including which jurisdictions are already signed up and how it is likely to apply to different business models, read our global advisory: How will the OECDs Crypto Asset Reporting Framework impact your business.
